G.K. MITTER, J.

1. IN this reference the only question for the opinion of this Court is whether the assessee-association is a public charitable institution entitled to exemption under s. 4(3)(i) of the Indian IT Act.

2. THE assessee was incorporated as a company not for profit under s. 26 of the Indian Companies Act, 1913. As the determination of the question depends upon the construction of its constitution it is necessary to set out the relevant clauses in its memorandum of association. Clause 3.--The objects of the association are to promote and develop home industries, arts and crafts, in the Presidency of Bengal and to do all things necessary for the attainment of the object :

(1) to collect and publish or otherwise furnish information with respect to home industries, arts or crafts, in Bengal; (2) to establish or assist home industries-- (a) by the purchase of the raw materials and articles necessary for their manufacture, by advance of money or furnishing of guarantees to encourage such manufacture and the acquisition of craft secrets, rights or methods of work; (b) by promoting the formation of credit societies or other associations having for their object the exten